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Denmark enacts new rules on international taxation

03 December 2020

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Tax Alerts, Legislation & Policy, Na...

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Denmark

On 3 December 2020, the Danish Parliament enacted Bill No. L 28 with changes to:Transfer pricingPermanent establishmentsForeign lossesTransfer pricingThe law significantly strengthens the Danish transfer pricing rules as follows:Transfer pricing (TP) documentation must be submitted to the tax authorities no later than 60 days after the deadline for the filing of the annual corporate income tax return (generally due six months after year end). This will include both the master file and country specific file(s).The tax authorities are entitled to extend the 60-day deadline in extraordinary circumstances.TP penalties may be imposed if the TP documentation is not submitted within the 60-day...